On 19 April Treasury Secretary Scott Bessent's Office of Foreign Assets Control (OFAC) allowed General License U, OFAC's Iran-crude waiver, to lapse at 00:01 EDT with no Federal Register notice and no replacement instrument. The same Treasury Department, on the same day, signed General License 134B, the Russia seaborne-oil equivalent, extending Moscow's waiver to 16 May. OFAC does not sign General Licenses by accident, and the Federal Register carries both instruments from the same 19 April working day.
The White House presidential-actions index on 19 April recorded 51 days of Iran war with zero signed Iran executive instruments. Two non-Iran orders were signed the same week, a college-sports executive order and a mental-illness treatment order, so the signing pen was available. Iran simply did not get it. Put differently, Treasury signed Russia's waiver the same day it let Iran's lapse. One country's oil flows with written permission; the other's is being stopped at gunpoint without any.
For European refiners the practical question is whose US-sanctions paper their bankers can now present to a letter-of-credit counterparty. GL-U had been the cover for residual Iran-linked crude in Chinese and Turkish flows; GL-134B continues to cover Russian barrels the G7 price cap was designed to constrain. Shipping underwriters will read the same asymmetry into war-risk premiums: a hull carrying Russian crude operates under extant US paper, a hull carrying Iranian crude operates against US paper that expired at one minute past midnight and was not renewed.
A counter-view from Treasury's defenders is that GL-U's expiry is a technical consequence of the blockade, not a signed policy, and that allowing it to lapse is itself a policy decision Congress has not contested. That reading still leaves the asymmetry on the page. The Trump administration's Russia posture has been argued on diplomatic grounds for months; the Iran posture is now operating without the paper a foreign court would expect to see.
